Health care organizations must determine how their wastes are regulated prior to disposing of them. Unfortunately, this is not an easy process as there are many applicable regulations at both the Federal and State level. These include (but are not limited to):
- Controlled substance requirements in accordance with the Drug Enforcement Agency (DEA)
- Hazardous waste regulations in accordance with the Environmental Protection Agency (EPA) and individual state requirements
- Infectious waste requirements in accordance with state-specific requirements (requirements greatly vary between states)
It is also important to keep in mind other requirements that are typically associated with health care waste management:
- The Occupational Safety and Health Administration (OSHA) for safely working with chemicals and bloodborne pathogens
- The Department of Transportation (DOT) for shipping of hazardous materials
- Local Publicly Owned Treatment Works (POTW) who regulate what can be placed down the drain
Simply put, health care wastes generally cannot be flushed down the toilet, poured down the drain or put in the trash dumpster.
Below we discuss some of the more common types of health care wastes and how they need to be managed.
Health Care Waste Types
What Are They - Common examples of controlled substances include morphine and hydrocodone. Take a look at the DEA's Controlled Substance Schedules for a comprehensive list.
What Requirements Apply - When disposing of controlled substances, you must meet the DEA's non-retrievable and destruction standards (see the entire DEA disposal regulation). Put simply, this requires that you follow the below two-step process:
- Placement into a suitable neutralizing media or use of a solidifier for liquid controlled substances.
- Placing the neutralized container into a non-hazardous pharmaceutical waste container that will be sent out for incineration.
What Are They - Some medications meet the definition of hazardous waste under the Resource Conservation and Recovery Act (RCRA). Below is an outline of the different categories of hazardous waste that can apply to health care waste as well as a few examples for each category.
|Hazardous Waste Type||Definition||Examples|
|Listed on RCRA P-List||These chemicals are specifically listed as hazardous wastes. However, in most States, to be managed as a hazardous waste they must be: (1) the sole active and (2) not have been used for their intended purpose.||
**This includes empty containers unless they have been triple rinsed.
|Listed on RCRA U-List||These chemicals are specifically listed as hazardous wastes. However, in most States, to be managed as a hazardous waste they must be the sole active and not have been used for their intended purpose.||
|Characteristic for Ignitability||Has a flashpoint less than 140F, is a DOT oxidizer, or is a flammable aerosol.||
|Characteristic for Corrosivity||Has a pH less than 2 or greater than 12.5.||
|Characteristic for Reactivity||Can cause explosions, toxic fumes, gases, or vapors when heated, compressed, or mixed with water.||
|Characteristic for Toxicity||Contains regulated levels of one of 40 chemicals.||
(1) Epinephrine has been excluded from the definition of hazardous waste at the Federal level, but some states have not adopted that exclusion.
What Requirements Apply - If you generate hazardous waste, specific requirements will depend on the quantity generated each month. These requirements will generally include:
- Registration with EPA to obtain an EPA ID Number
- Managing waste materials in appropriate and labeled containers while on-site
- Routinely inspecting waste containers
- Training employees
- Having some emergency plans in place
- Documenting waste shipments
What Are They - Infectious waste (also known as regulated medical waste) is generally considered to be any waste with the potential to spread disease through blood or other types of contamination if not handled properly. Common examples include:
- Liquid blood or other potentially infectious body fluids from humans or research animals
- Wastes that release blood or other potentially infectious body fluids when compressed
Caution! Check your state's regulations as not all states have adopted OSHA's "saturated" definition with respect to what is considered an infectious waste (e.g. some states require that any waste containing infectious material to be managed as regulated waste).
- Sharps from either human or animal use
- Human and animal vaccines
- Human or animal body parts such as organs, tissue, and surgical specimens
- Infectious cultures and laboratory equipment contaminated with such cultures
What Requirements Apply - Most states have strict regulations on how to manage infectious wastes. Common requirements include:
- Preparation of an Infectious Waste Management Plan
- On-site storage requirements (including packaging and labeling requirements)
- Employee training (may include both waste management and DOT shipper training)
- Proper disposal using a registered shipping company
It is also important to note that OSHA has a comprehensive set of regulations that also includes requirements similar to these (and many more). You can find OSHA's Bloodborne Pathogens regulations at 29 CFR 1910.1030.
Non-Hazardous and Non-Infectious Waste
What Are They - If a waste material does not fall into any of the above categories, it likely falls into this category. However, this is by no means an exhaustive study so please carefully review your State's regulations when characterizing health care industry wastes.
What Requirements Apply - These waste items may be wrapped securely in trash bags for disposal in the normal trash.
Other Frequently Asked Questions
What About Wastes That Are Both Hazardous Waste and Infectious Waste?
You will need to manage these wastes in accordance with both hazard sets of regulations.
What About Sharps?
OSHA defines a sharp as any object that can pierce the skin such as:
- Razon Blades
- Dental anesthetic carpules containing residual blood
- Wires, sutures, and dental files
If these items contain infectious components (such as blood), they must be managed in accordance with infectious waste regulations as well placed in an FDA-compliant sharps container.
How Can EHS Software Help Me?
EHS Software, such as Ecesis, can help you characterize and track your waste, train your employees, complete recurring inspections and manage your recurring tasks. Centralization and automation of these processes will help make sense of complex regulations and save you time so you can focus on caring for your patients.